The press seems to be full of people frothing at the mouth over suggestions by Associate Health Minister Peter Dunne that the manufacturers of ‘legal highs’ should be required to provide safety information on their products before they are allowed on New Zealand shelves. This comes on the back of the minister announcing a Temporary Class Drug Notice banning a substance called EAM-2201 found in samples of a synthetic cannabis product. EAM-2201 appears to be a synthetic hybrid of two known cannabinoid compounds previously used as active ingredients in synthetic cannabis blends, but which are now banned in many countries.
What has really got people upset is the suggestion that dogs and rats will be force feed ‘legal highs’ until half of them die (the so-called LD50 assay [the lethal dose at which 50% of animals are killed]) in an effort to provide us with some information on their ‘safety’. There is lots of talk of this test being banned in the UK. It’s certainly banned for the use of cosmetic testing in Europe but I’m not sure about all chemicals.
Four things strike me about this story:
1. Are the majority of people aware that there are products for sale which have essentially never been tested on humans or animals?
2. That people who take ‘legal highs’ are probably taking them because they are a legal alternative to illegal drugs. Ironically, we know an awful lot about illegal drugs so they are probably the safer alternative. It is also ironic that it is perfectly legal to buy tobacco and alcohol, two extremely harmful ‘drugs’.
3. That Peter Dunne and almost everyone else who commented on the story* has no idea how animal testing is regulated in New Zealand. This is what I want to comment on a little later.
4. What does everyone mean by ‘safety’ in reference to these ‘legal highs’? Do they mean LD50 (presumably we would want to know the dose likely to kill people rather than rats and dogs)? Or do they want to know if they are addictive? There was mention in the original press release banning EAM-2201 of its use being tied to “elevated heart rate, vomiting, anxiety and psychosis”. So is it anxiety and psychosis we are interested in? These are important questions, as they will determine the kinds of tests that need to be performed.
In New Zealand we have the Animal Welfare Act 1999 which came into force on the 1st January 2000. There is information about the Act on the Ministry for Primary Industry’s website here. Part 6 of the Act relates to the use of animals in research, teaching and teaching. It sets out that:
1. No research, testing or teaching may be carried out on any live animal unless the person or organisation involved holds an approved code of ethical conduct.
2. No project may proceed without the approval of an animal ethics committee (AEC) established under such codes.
3. The AEC comprises 3 members from outside the organisation holding the code of ethical conduct.
4. The AEC is subject to independent review.
5. The AEC will only approve research if there is a proven benefit and if that benefit outweighs the cost to the animals used.
6. The AEC will promote the use of the 3 Rs: replacement of animals with a non-living or non-sentient alternatives, reduction of numbers to the minimum required, and refinement of techniques to minimise harm and suffering.
So let’s get one thing clear. It is highly unlikely any ethics committee would approve LD50 tests for party pills in New Zealand. I should know because I’m a member of one. So should these untested products be on our shelves? And if they are to be tested, what are the criteria? It’s a tricky one. Personally I’d like to see how they do on the spider web test!